The FTA Drug & Alcohol Audit Process
George Y. Gilpatrick Jr. & John B. MorrisonSenior Auditors
What Should I Expect?
What You’ll GetProgram EvaluationTechnical AssistanceRegulatory Training
Notification
When does it occur?
Why was I selected? (and did I do anything wrong?)
What does the audit team need?
The Schedule Is the schedule flexible?
How long will the audit team be on-site?
Will the Region be involved?
What if we just got audited? From a different agency?
Pre-Audit Materials
What do I need to send? Completed contact information & schedule Copy of most current policy ALL testing records from examination
period: Random Pre-Employment Post-Accident Reasonable Suspicion Return-to-Duty and Follow-Ups if done
Pre-Audit Materials
Names of all vendors (MRO, SAP, Collection Sites)
Laboratory data Organization chart (if on hand) Names of individuals relevant to the
program (C/TPA officials)
Pre-Audit Materials
Optional Material:
Collector certificates
MRO certifications
SAP certifications
Pre-Audit Materials
Submit all materials on or before the listed submission date
Contractor data should come through Grantee
As much electronic information as possible
All Electronic Submissions
Fort Wayne, IN
Santee Wateree, Sumter, SC
State of Tennessee
Pre-Audit Materials
1 Copy to Team Leader (Contractor)
1 copy to USDOT Volpe Center
Q: How long will the audit take?
On-Site Visit “Whoa… Why the group?” Entrance Conference begins Audit If building is secured, auditors need
access passes Auditors need office or conference room DAPM needs to be available for majority
of time Operations Chief or Supervisor may also
be needed
4 Parts of the Audit
#1: Interviews with Transit System
DAPM/DER Interview (30-90 minutes)
Discussions with Operations Personnel
Discussions with HR
#2: Review of Records
Random tests Pre-Employment tests Post-Accident tests Reasonable Suspicion tests Return-to-Duty/Follow-Up tests Training schedule Route schedules
#2: Review of Records
Accident Reports and Files Employee Rosters Memos to and from Vendors Arbitrations and Disputes Internal Memos MRO verifications Lab reports
#3: Evaluation of Vendors
Phone interviews with:
MRO SAP (Must be local!) C/TPAInterviews are conducted in person when
possible
#3: Evaluation of Vendors
Visit to Collection Site for MOCK-Collection
Procedures at site closely evaluated Collection site and enclosure
inspected Staff interviewed
CONTRACTORS
Don’t Forget:
Contractors are YOUR responsibility. This includes service providers and security firms, in addition to vendors
Technical Assistance
Ask audit team to show you what they are doing. Learn how to inspect
Chains-of-Custody and other documents
#4: Technical Assistance
Auditors identify deficiencies Work with Transit system to develop
corrective actions Help with operational difficulties Help with administrative difficulties Suggest additional assistance Are available even after the audit
ends
Exit Interview
Auditors generally leave the guest-list to the Grantee
Usually between 30 and 60 minutes Report is an exceptions report
Will there always be findings?
State of Kansas
MUNI in San Francisco
Audit Team issued compliance letter on the spot during the exit interview
What Constitutes a Finding?
A direct violation of the federal regulations (49 CFR Parts 40 & 655)
Includes failure to submit pre-audit information
Does NOT include best-practices interpretations
Does NOT include any auditor preference
Transit System Rights
As the audited entity, you are entitled to know the citation for each finding.
Ask EVERY auditor, trainer, consultant, or “expert” to cite the regulation when a requirement is mentioned.
If a citation can not be found, it is NOT a finding.
Transit System Rights
As the audited entity, you are entitled to present information that will mitigate findings before the final report.
Response Period
Either 45 or 90 days to submit corrective actions response
Generally, policy revisions may be submitted at any time
Stay in contact with Audit Team Leader
Ask questions
Response Period
Responses evaluated by auditors
May require addition corrective action
Compliance
Compliance letter issued!
Am I Done?
Can still ask regulatory or compliance questions
Can still contact the audit team leader or team members
Can still ask for assistance
Questions & Answers
George Gilpatrick & John Morrison
will be available for questions
immediately following this presentation
Room 209-210